I am writing to comment on the Environmental Impact Statement (EIS) prepared by GHD for Plasrefine’s proposed plastic recycling facility at Moss Vale, titled “Moss Vale Plastics Recycling and Reprocessing Facility EIS”. Most of my comments relate to the section called Technical Report 3 – Air Quality and Odour, which I will refer to as “the report”.

Please also see my attached document which discusses my objections in more detail, and includes scientific references. Here I will summarise the most important points:

The report omits important information about the impacts on human health from volatile organic compounds (VOCs) and other airborne emissions, and presents insufficient detail about how Plasrefine would manage emissions. The report only assessed 3 individual VOCs (benzene, toluene and styrene), but there are many more VOCs and other noxious compounds that can be released when plastic is melted, some of which are carcinogenic or neurotoxic; a few are associated specifically with waste plastic. The report does not mention these problematic substances, or assess their impacts on the health of the community, or on Plasrefine’s own employees.

The report relies on the stated assumption that the plastics being heated will include only polyethylene (PE), polypropylene (PP) and polyethylene terephthalate (PET). The EIS states, however, that the facility will also process acrylonitrile butadiene styrene (ABS), and up to 20,000 tonnes of polyvinyl chloride (PVC) per year. Both of these plastics should have been included in the report’s assessment of air quality impacts, particularly PVC which will represent around one sixth of all plastics processed at the facility and will therefore contribute significantly to its emissions.

The toxic emissions from heating PVC include hydrogen chloride, vinyl chloride (a known carcinogen), and dioxins, which are “among the worst materials for human health impacts." The exclusion of PVC from the report casts doubt on the validity of GHD’s claims that airborne emissions from the Plasrefine facility will be “low” or benign.

Studies of plastic recycling processes and facilities elsewhere in the world have documented impacts on human health and wellbeing as a result of airborne emissions. The impacts on people living near other plastic recycling facilities included respiratory and skin problems, increased cancer risk, and reduced quality of life as a result of unpleasant odours. Impacts were sometimes experienced by residents more than a kilometre away, but were most severe for those closest to plastic recycling facilities. The EIS does not address these human health issues, nor are those studies included in its reference list.

The report does not provide information about the efficiency of the proposed systems for treating air emissions within Plasrefine’s facility, and does not state what percentage of emissions these systems would capture. This is an important detail, since it will determine the amount of airborne pollutants released into the surrounding environment. Without this information, how can it be confidently stated that emissions will be “low”?

At previous community presentations, GHD stated that Plasrefine would use “common techniques that are able to capture 99% of emissions”. Even if this is true, it still amounts to a large impact on air quality. Effectively it means that untreated emissions from 1% of the 120,000 tonnes of plastic to be processed each year (around 1200 tonnes per year, or more than 3 tonnes per day) will be vented straight to the surrounding neighbourhood. If some ordinary citizen was to melt down 3 tonnes of plastic per day in their backyard, with no protection for the neighbours, it seems highly unlikely that would be considered acceptable anywhere close to a residential area.

A failure or inadequacy of the airborne emissions treatment systems, or unusually large emissions if a fire impacts on the facility, could create serious off-site risks or offence to people, property or the environment due to the toxic nature of the substances involved in melting and burning plastics. A build up of these toxic substances in the nearby environment over time could also represent a significant hazard. Therefore, I would suggest this proposal falls into the category of potentially hazardous or offensive development and should be assessed under SEPP 33.

The list of “sensitive receptors” in section 4.1 of the report omits the many people in the general community >500 m from the proposed facility who are vulnerable to impacts from VOCs and other airborne emissions. These include young children, the elderly, and people with respiratory issues such as asthma, or other health issues.

The meteorological data presented in section 4 shows the prevailing winds blow mostly from the North/Northeast in spring and summer, directing emissions straight towards Moss Vale’s central residential and business areas for around half the year. Spring is also the time when high wind speeds occur most frequently, further increasing the likelihood of airborne emissions impacting on the town. Moss Vale is a growing community with several housing developments under way, so these airborne emissions could impact on an increasingly large number of people.

It is not clear whether there are effective barriers to air movement between the processing areas where emissions will be generated and the unloading area where trucks will drive in. If air can flow freely between these areas (as appears to be the case from the diagrams of the buildings’ internal layout) then what will prevent untreated emissions escaping whenever the roller doors open to allow trucks in and out?

The effectiveness of the proposed methods will be to separate the different kinds of plastic, and the consequences if plastics become inadvertently mixed and are melted at inappropriate temperatures at a result, should have been discussed in the EIS.

It is not clear at what temperature the extrusion process in Building 1 will occur, although this temperature will significantly affect the level of toxic emissions produced at this stage of the process. The extrusion process in Building 2, where plastics are reformed, will be done at “less than 280˚ C”. This is not particularly comforting, since many plastics emit harmful substances at much lower temperatures than this. A more precise range of treatment temperatures should be provided for each type of plastic in order to realistically assess the emissions.

Table 7.4 gives insufficient information about how Plasrefine will assess and monitor VOCs and other noxious emissions. There is no information as to how, by whom, how often, and what specific kind of emissions will be monitored. These are important details, since a failure of the emissions capture systems could result in unacceptable impacts on the nearby community if this failure is not detected quickly.

The proponent does not appear to have run a similar facility before, so their ability to run the plant safely and successfully is unknown.

The EIS involves transporting plastics a long distance from their point of origin in the cities, creating a large carbon footprint.

The proposed facility is much larger than other similar facilities in Australia, and accordingly could have much larger impacts on the community and local environment.

As climate change intensifies over the next few decades, extreme weather events will increasingly disrupt transport to and from Moss Vale. The haulage route between Wollongong and Moss Vale is particularly problematic, even though it is a smaller distance than the route to Sydney.

Many of these problems could be mitigated by having two or three smaller facilities located closer to the outskirts of Sydney, Canberra and/or Wollongong (although still at sufficient distance from residential areas to protect human health).

The local roads in the Moss Vale area do not seem adequate for the increased heavy traffic. All of the three local access roads to the proposed site appear to have significant problems associated with their use. It seems likely that construction of the new access road will be delayed or even prevented altogether due to land acquisition issues, causing unacceptable impacts on Beaconsfield Road, and/or a significant reduction in the quantity of plastic waste the facility can receive.

The proposed site has previously been described by Wingecarribee Council as “flood prone” land. In 2019 a development application to subdivide the site was refused by council on this basis. Recent flooding events in NSW have demonstrated that the unexpected is happening more frequently, and many existing flood maps may need to be reassessed.

The need to move a watercourse to build the facility is a red flag. This cannot be done without having serious impacts on the ecology of the creek.

I am also concerned about the proposal’s potential impacts on tourism, which is a large source of revenue for the Southern Highlands. Why would anyone want to go on holiday near a huge plastic recycling factory that may smell bad, make them cough or itch, or cause them to develop cancer?

While recycling plastics is certainly desirable and necessary, it needs to be done in a way that will protect people and the environment. If the local community cannot be guaranteed protection from noxious airborne emissions and other impacts, then using the precautionary principle, the Plasrefine facility should be located much further away from residential areas.

There are so many issues with this project. A lot of these will not be answered satisfactorily until the plant is up and running , at that stage there will be no going back.
- Heavy vehicle trucks 11 hrs a day 7 days a week continually passing residential housing only 10-15 meters from roadway (Beaconsfield ' Lackey and Lytleton Rds).
-How far will this continual noise penetrate into the surrounding suburban area. Peoples lives impacted by the relentless noise. Their sanctuary from the stresses of daily life and work taken away from them.
-The safety issue of heavy vehicle transport sharing residential roads with school children ,aged from 5 years up , with no footpaths forcing them to walk on the edge of the road. Some of these roads can barely accommodate two passing passenger vehicles let alone these monster trucks. This is a potential tragedy waiting to happen. These residential roads should be completely off limits to Heavy vehicle usage and the Recycling company should not proceed with any works until another access rd is constructed.
-water usage by the processing plant and dependence on town water are a real concern, especially during times of drought.
-contamination and volumes of water being discharged into the sewerage system.
-Air pollution ,what toxic chemicals are going to be released into the air by this process. What are the safe limits and who will monitor these pollutants . What action will be taken for non compliance.
Conclusion- This is not the right site

The high flow of trucks and heavy vehicle traffic through Moss Vale and surrounds will congest and damage our roads, all of which is under strain as it is.
The Plasrefine plant will contribute significantly to noise, air and water pollution in our community.
There are better sites for this type of project. This is proposed to be within a few hundred meters of residential houses and will cause a major disruption (24hrs a day) and discontent to the people living close to the site.
There's been a very poor effort to consult and involve the community tin the planning process. Offering 140 jobs is not enough and many of those will likely come from out of area anyway.

This project is situated in the wrong Location - it is an envrionmental, health and social hazard to a growing poplulation in Moss Vale and Surrounds . It is most inappropriate and there has been very poor communication with the local population.

Submission attached

Dear Manager,
The proposal currently sits in a tourism destination site and will ruin a major industry of the population. Times have changed, we have major flooding and fire and severe weather risks leading to population stress and mental health issues. This proposal will put water and food security at risk on top of the economic foundation of the Southern Highlands, a major tourism destination for functions, conferences, weddings, outdoor experiences, conservation and education. Most significantly the proposal would create increased health issues by reducing air quality and exposing environment to toxins. The Operator has no prior record in this highly risky enterprise.
The EIS, if full of technical errors, inconsistencies and does not address many areas of concern such as occupational safety and hazard at the plastic melting stage, emergency measures in the event of a factory fire, no details of plastic sludge disposal, protection of Riparian zone and so on. The EIS does meet the required standards and the level of details expected of an EIS for such scale SSD.
Based on the requirements of the SEPP 33 the proposed development is potentially hazardous in nature as it involves plastics and polymers for reprocessing. While the plastic products prior to recycling or final products may not be hazardous and toxic there are some stages in the reprocessing of each of those plastics are hazardous and toxic
The significant residential areas within the Moss Vale and the surrounding rural residences as well as Early Childhood Learning Centre and other facilities will be significantly compromised if the proposed plant will be approved.
The Environmental Impact Statement (EIS) does not address adequately any possible hazard:
· No buffer zone for air quality and odour.
· No buffer zone for noise and vibration.
· No buffer zone for fire hazard
· No plan for evacuation in case of any accident including surrounding residences
Thank-you for addressing the exceptional risks associated with this proposal.

I object to this proposal in its current form. My reasons are set out in the attachment.

Alan Lindsay